A recent decision by the **Eastern District of California** has affirmed that federal jurisdiction is applicable in the case of **Mary Catherine Baldi** v. **Service Finance Co. LLC**. On **September 23, 2025**, the court denied Baldi’s motion to remand her consumer protection lawsuit to state court, maintaining that the allegations presented were sufficient to establish federal jurisdiction.
Baldi, representing herself, sought to return her case to California state court on the grounds of standing. She claimed that she had not been harmed by the actions of the defendant, despite outlining several grievances. These included a dispute over an additional charge of **$1,096.20** after she had fully paid her HVAC financing. Furthermore, she alleged that the lender had placed **47 automated calls** after she revoked consent and reported her account as delinquent to credit bureaus, which negatively impacted her credit score.
In her motion to remand, Baldi argued four key points: first, that **Service Finance** failed to demonstrate **Article III standing** in its notice of removal; second, that state courts have concurrent jurisdiction over federal statutes; third, that the removal was a tactic to evade state discovery rules; and finally, that her claims under the **Rosenthal Fair Debt Collection Practices Act** introduced novel state law issues that should take precedence.
Service Finance countered these assertions by stating that the removal was justified as the complaint raised significant federal questions. The defendant emphasized that once a case is properly removed to federal court, the state court loses its authority over the matter. They also argued that the allegations presented in Baldi’s complaint sufficiently established federal jurisdiction.
The court addressed Baldi’s standing claim first, concluding that her allegations constituted concrete injuries adequate to meet the **Article III** threshold. Despite Baldi’s contention that cases under the **FDCPA** require a demonstration of actual harm for federal jurisdiction, the court noted that she did not challenge her own claims of injury. Instead, her motion inadvertently acknowledged these injuries, which included a rejected payment of **$8,504.65**, the unexplained charge of **$1,096.20**, and adverse credit reporting leading to a **$13,000** reduction in her credit line.
The court clarified that the process of removal does not imply an admission of wrongdoing by the defendant. Under **Article III**, it is sufficient for a plaintiff to allege an injury related to a federal statute; the defendant is not required to agree to these allegations for the removal to be valid. This principle aligns with the Ninth Circuit’s ruling in **Jones**, which affirms that federal jurisdiction can hold even if the complaint is later dismissed for not sufficiently alleging a statutory injury.
Baldi further contended that her case should revert to state court due to the concurrent jurisdiction of state courts over the relevant statutes. The court responded by explaining that concurrent jurisdiction permits initial filing in state court; once the case is removed, federal jurisdiction is maintained.
Additionally, the court dismissed her claims regarding the removal being a strategy to avoid state discovery obligations, stating that fears of evidence spoliation were speculative. Differences between state and federal discovery rules do not warrant a remand.
Finally, the court established that Baldi’s claims under the Rosenthal Act were factually intertwined with her federal claims, which justified the exercise of supplemental jurisdiction. The ruling underscored that once a complaint raises federal claims such as the **TCPA**, **FCRA**, or **FDCPA**, federal jurisdiction is appropriate, and mere differences in procedural rules between state and federal courts do not justify remanding the case.
In conclusion, the court’s decision reinforces the principle that federal jurisdiction can be upheld in consumer protection cases involving federal statutes, clarifying the standards for standing and the implications of case removal.
